EBA calls on counterparties to seek authorisation for using ISDA SIMM margin models

The European Banking Authority (EBA) has launched a data collection, through competent authorities, to identify EU counterparties who must apply to the EBA for validation of the ISDA standard initial margin model (SIMM) under the European Market Infrastructure Regulation (EMIR) and their contact persons. All financial and non-financial counterparties exchanging initial margins calculated using ISDA SIMM, directly or indirectly, must apply for authorisation from their competent authority, as mandated by Article 11(3) EMIR and the EBA's no-action letter of December 17, 2024. The information provided will be used to onboard counterparties onto the EBA's validation system during the first half of 2026, ahead of counterparties' applications to the EBA for validation of ISDA SIMM expected in the second half of 2026. Failure to obtain validation will prohibit the use of ISDA SIMM until counterparties rectify their status with the EBA. A list of validated counterparties is expected by the end of 2026.

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